Making your own cosmetics: cost, time, minimums

You first need a clear idea of who the product is for and what it should do. Everything else is built from that, from the formulation to the packaging and the documentation. Our process starts with a conversation about the product's purpose, target customer and intended market. Then come the formulation, a prototype, testing, documentation and manufacture. The documentation and the notification are our part.

You do not need every answer at the first call. Knowing who you sell to and what you want to say is enough.

Talk to us. We are a boutique manufacturer in Slovenia, developing and filling cosmetics for other people's brands. We work with experienced companies and with people who are only beginning. What matters is knowing that this is a technical project which will ask for your involvement, your patience and a clear sales strategy. Everything else is on us.

Most of our projects are bespoke. The formulation is designed for you and stays yours. If you want a faster and cheaper route, we can also offer a ready-made formulation as white label. In that case we concentrate on the packaging and the manufacture.

White label means the manufacturer develops one product and sells it to several customers. Each markets it under its own brand and in its own packaging, while the product inside is the same or barely altered, in scent or colour say. The advantage is speed, since the documentation and the testing are already in place. The drawback is that the formulation itself offers limited differentiation from competing products using the same or a similar base. For brands that compete primarily through formulation, performance or exclusivity, a standard white-label base may therefore be less suitable.

Very little can be altered. Plant extracts, fragrance and viscosity can be changed and a limited set of actives added. Changing the preservative or the emulsifier, or raising the actives above the approved range, means a new stability test and a new safety assessment, and at that point it is no longer white label but development.

It is chosen mostly by customers who build on need or on volume rather than on innovation, hand creams or UV protection for instance. We concentrate on products that become the intellectual property of your company. Formulations are not repeated and stay a trade secret.

Where a bespoke product is commissioned, ownership of the formulation passes to the customer. The product is yours, documentation included, and the formulation is never offered to anyone else. With white label the ownership stays with the laboratory, since the formulation was prepared in advance. You know that from the outset.

All of it is a matter of agreement. If yours is a particular case, write to us.

Yes. An existing formulation can be taken over, optimised and manufactured here. We also optimise existing formulations so the price in our production comes down while the properties and the efficacy stay as they were. If the product is made outside the EU and you want to import it, you need a PIF with a safety assessment. We prepare those for products not developed here as well. The result can also be negative and show that the formulation has to change.

A clear product concept, developed as far as you can reasonably take it, and competitor or reference products with properties you like. They need not be close relatives of what you have in mind. You also need to decide whether you are aiming at a particular certificate, what packaging you picture, and who your customers are.

An existing company helps for the sake of cost deductions. Without one you can begin as a private individual.

It is the analysis of an existing product by another supplier, from which you would like to draw inspiration. Your product will not be chemically identical to the original, but it can carry very similar properties, texture and effect on the skin.

There is no honest rule-of-thumb figure. The range is very wide and depends on the kind of product, the complexity of the formulation and the quantity. Write to us with your requirements. Once an NDA is signed, we prepare a quotation. For products both developed and manufactured here we can offer on average up to 25 per cent less, and a faster route, than for products developed elsewhere. Formulating here lets us optimise our own process and use our established supply lines.

It depends on the formulation, the packaging and the size of the batch. The larger the batch, the lower the cost per unit. Raw materials are not the whole of it. Packaging, filling, documentation and testing are a substantial part, and they are spread across the number of units in the batch. That is why the difference between a hundred and a thousand units is so large.

The smallest batch depends on the kind of product and the packaging chosen, so an exact figure is not possible without knowing the formulation. We work in three classes of vessel, 1 to 5 litres, 15 to 30 litres and 50 to 200 litres. How many units that comes to depends on the size of the pack. Fifty litres is a thousand units of a 50 ml pack, and two hundred and fifty of a 200 ml one. So the pack size is worth settling before the vessel.

A smaller batch costs more per unit, but it is not impossible. Boutique manufacture is the reason we exist.

For a genuinely new product, reckon realistically on eight months to a little over a year. The stability test takes the longest at 3 to 4 months, with the lead times on raw materials close behind. The formulation and the prototypes take 4 to 8 weeks and the documentation and notification about a week. The commonest cause of delay is not the formulation but the packaging and the print. Which is why the packaging is worth discussing early.

The laboratory slot is reserved on receipt of an upfront payment, which is normally the full project amount. The exception is a waiting list. Then the payment can be split into instalments, though all of them fall due before the work begins.

The formulation and the prototypes, the testing relevant to the specific product, the documentation and notification, the raw materials, the packaging and print, and the filling. Additional studies, dermatological or clinical, are run by outside panels and laboratories at their own rates. Where you need them, we plan them together.

It begins with the market and the audience, then the formulation is designed and a first prototype made. We test the prototype together, note what is wrong with it, correct the formulation and make a new version. That is repeated until the product does what it should. Then come the product-specific testing and safety work, the documentation and manufacture.

The knowledge here comes from cosmetology, pharmacology, dermatology, laboratory biomedicine and biochemistry. Behind that stand years of developing products for the pharmacy market and for the general market.

Broadly they divide into the technological base and the actives. The base gives the product its stability, safety, look and feel on the skin. Emulsifiers, preservatives, pH regulators and humectants belong here. The actives give the effect. In practice, the technical base is often more demanding to design than the marketing focus on active ingredients suggests.

Yes. A formulation can be adapted to the conditions of a particular quality certificate. Certificates are awarded by independent European and worldwide bodies, each with its own rules. So the decision has to be taken before development begins, and we need to know about it.

Most products aim at a pH between 4.5 and 5.5. That is close to the skin's own acid mantle and suits most preservatives as well. AHA and BHA preparations need a lower pH, and preparations thickened with carbomer a somewhat higher one.

Yes. Vegan means no materials of animal origin, and in principle it asks nothing unusual of a formulation. The exception is very specific targeted effects that can only be reached with non-plant peptides. There a compromise may be needed.

Yes. You receive a prototype to try and to judge. On your notes we correct it and send a new one. You will never receive a prototype that is not safe to use. That part is settled at the choice of ingredients.

The office is in Ljubljana and the production in a small village near the coast. We rebuilt an older house entirely and fitted it out to the standards of pharmaceutical manufacture. Instead of renting a typical industrial unit we chose our own home ground. Everyone involved lives close by, which keeps transport to a minimum.

We manufacture liquid to medium-viscosity care products. Creams, serums, lotions, gels, toners, shampoos, oils and the like. We do not make hard soaps and we do not make decorative cosmetics with pigments, which includes lipsticks and powders. We do make tinted care products, where colour is secondary. Skincare is our speciality. We see beauty in your skin.

We do not fill pressurised sprays such as deodorants or hairsprays. That is part of our decision on the environment. We do not fill tubes because of the limited precision of the process, which leads to a high share of wasted packaging. On a tube run up to a fifth of the packaging is lost, because the artwork shifts as the end is welded. We will suggest alternatives that waste less.

Filling is done from the top of the pack, followed by fitting the cap or the dispenser. The process is built so the product meets no contaminants on its way into the pack. Production is almost entirely automated, which is what makes controlled hygienic operations and repeatable filling accuracy possible.

All process water comes from our own rainwater catchment in a village free of smog, and is then mineral-purified and enriched in our own preparation. It is purified to a high level of purity suitable for controlled cosmetic manufacturing, to controlled parameters suitable for cosmetic manufacturing. Water is the largest single ingredient in most products, so this is not a detail.

Confirmed customers are of course welcome to visit us. Bees will greet you at the entrance in fine weather. A little caution with them is advisable.

All of the energy comes from our own solar array, we prepare our own water, and chemical waste is small by design and properly disposed of. In products developed here, 95 per cent of the raw materials are of natural origin and fully biodegradable. Because we all live beside the production, the transport footprint is small as well. The owner lives next door, in the same building.

Mostly pharmaceutical-grade materials of European origin, supported by the relevant specifications, documentation and test reports. Their identity, purity and relevant impurity limits are controlled against defined specifications; pharmaceutical grade does not mean literally impurity-free. Every batch is traceable, which allows us to verify its origin and documentation if anything needs to be clarified later.

We use selected Asian raw materials, but only where they meet our quality requirements and come with appropriate specifications, documentation and test reports. Quality is the first rule and price only the second. We do not depart from that, not even at a customer's request. Origin alone does not determine the quality of a raw material: China, like other manufacturing regions, is also home to producers of high-quality cosmetic ingredients, including vitamin C. What matters is the supplier, the specification, traceability and knowing exactly what you are buying and from whom.

A raw material without proper testing and documentation can carry unknown impurities, heavy metals or residues from its own manufacture. If something then goes wrong, there is no way of establishing what. Responsibility for the product lies with whoever places it on the market. Not knowing what your product contains is itself a form of negligence.

Cheap materials of low purity without documentation have been on the rise for some years. You will not meet them here.

We work to the principles of ISO 22716 for good manufacturing practice in cosmetics, ISO 9001 for quality management and ISO/IEC 17025 for laboratory competence. Certification by an external assessor is planned for the future.

A PIF, the product dossier, containing the safety assessment and the relevant supporting test data, plus notification to the European CPNP portal. When the product is developed with us, the documentation is part of what you receive. We handle that documentation as part of the project.

The PIF is the product dossier, a kind of identity card. It holds the details of the product, its ingredients, the formulation, the safety assessment and the test results. Without it the product may not go on the EU market. That holds for products you only import and resell as well.

The safety assessment is a technical review of every raw material used, its dose in the product and the calculated toxicity parameters. The cosmetic product safety assessment must be carried out by a person holding a university-level qualification, or an officially recognised equivalent qualification, in pharmacy, toxicology, medicine or a similar discipline as required by Regulation (EC) No 1223/2009. Where a specialist formulated the product, the safety assessment only confirms that it was built safely.

CPNP is the European portal to which every cosmetic product has to be notified before it is sold on the EU market. Notification is mandatory and asks for technical specifications. It is done by the responsible person, that is the company placing the product on the market.

The responsible person is the company that answers for the product on the EU market. If your brand places it on the market, that company is you. Its name and full address have to be printed on the primary pack.

The documentation we prepare follows the European regulation and holds for the EU market. Outside the EU other rules apply. The United Kingdom, Switzerland and the United States each require their own notification and, as a rule, their own responsible person or representative in that country. The country of origin and translations are often required as well.

Tell us where you intend to sell, and let us discuss it before development begins.

The same as everywhere in the EU. The central text is Regulation (EC) No 1223/2009 on cosmetic products. It requires a safety assessment for the finished product, sets prohibitions and restrictions for substances and positive lists for specific categories such as colourants, preservatives and UV filters, and lays down rules for labelling, notification and animal testing. The European cosmetics market is among the most strictly regulated in the world, which is good news for the person using the product.

The required testing programme is not identical for every cosmetic product. Before a product is placed on the EU market, its safety must be adequately supported in the CPSR and documented in the PIF. Depending on the formulation, water content, packaging, intended use and microbiological risk, the assessment will usually consider stability, microbiological quality and, where relevant, preservative efficacy testing (challenge testing). The product must also be notified through CPNP before it is placed on the EU market. The exact evidence required is determined for each product.

It checks whether the product stays as it should until the end of its shelf life. The product is put through cycles of thermal and other stress, which simulates accelerated ageing. It is best run in the very pack the product will be sold in. The packaging material can interact with the formulation, most often with the preservatives, and vapour tightness matters too.

It follows the guidance of ISO/TR 18811.

It checks for living microorganisms in the product, usually bacteria and moulds. It says whether the product is soundly built and how prone it is to microbial growth. It is worth repeating later in the product's life as well, particularly for products in jars, where the user reaches in with their fingers.

A challenge test, or preservative efficacy test, assesses how a formulation controls a defined microbial challenge over time after deliberate inoculation with specified microorganisms. When ISO 11930 is used, the result is assessed against the reduction and control criteria defined for the method at specified time points.

Passing the test does not simply mean that every introduced microorganism must be reduced to zero by the end of the study.

EU cosmetics legislation prohibits animal testing for cosmetic purposes within the scope of Regulation (EC) No 1223/2009. However, a “not tested on animals” claim is not automatically prohibited or misleading. Article 20(3) allows such a claim when its specific conditions are met. Some cosmetic ingredients may also have testing data generated under other regulatory frameworks, such as REACH, so the claim must be assessed and substantiated for the relevant product and supply chain.

It is not. This is one of the commonest misconceptions. EU cosmetics legislation does not provide a single positive list of all raw materials permitted in cosmetic products. It sets out prohibited substances, restricted substances and positive lists for certain categories such as colourants, preservatives and UV filters. Other ingredients must be assessed in the context of the finished product, its concentration, exposure and intended use as part of the cosmetic product safety assessment.

A dermatological test is run where the product genuinely needs one, or where you want to support a claim with it.

A patch test for skin irritation, ophthalmological testing, SPF testing for sun protection, and dermatological studies for particular properties, hypoallergenicity for instance. The Regulation treats cosmetics for the eye area and for children under three with particular strictness. There additional testing is prescribed.

Evidence for efficacy claims and any additional warnings come out of these tests.

That depends on the formulation and on how the product is applied, not only on how it looks. The kind of container decides how much air and how many micro-organisms reach the product over its life. An airless pack is the most protective, a jar the most exposed, a pump somewhere between. Glass is inert, plastic is lighter and cheaper.

On the packaging page there is a selector: choose the type of product and the particularities of the formulation, and it says which pack suits it and why.

Because it is an open system. Every use brings the product together with air and with fingers. It is often the best looking of them and microbiologically the most exposed. If you choose one, we take it into account in the formulation and in the choice of preservative.

The product is not in the container itself but in a pouch inside it, or in a container with a piston pressing it upwards. In either design, the unused product is largely protected from direct contact with incoming air and fingers during use. Airless packaging is therefore a strong option for oxidation-sensitive or microbiologically demanding formulations, although it is usually more expensive than a standard bottle or jar.

As a rule customers design and source their own packaging, together with their creative team. We advise on it so the pack also meets the chemical requirements of the formulation. Where that is beyond you, we supply the packaging. We order it as customers need it. The range covers bottles with various dispensing systems, glass and plastic jars, pumps and sprays, and other stock and non-stock packaging by arrangement.

For customers who develop or fill with us we prepare, for a supplement, a basic graphic design for the label carrying every mandatory statement, ready for print. The service is meant for less demanding projects. Anyone wanting a stronger visual identity should engage a graphic designer.

Glass, aluminium and good-quality plastic. Glass and aluminium are much in favour at the moment, though certain plastics have their own advantages. For products with essential oils we advise against PET and suggest glass or PP. It is worth knowing that essential oils attack the seals, the dip tube and the spring in the mechanism before they touch the body of the pack. So the specification of the mechanism matters, not only that of the container.

The boldest route is a shape of your own. That means real distinctiveness and a sense of luxury, and also a considerably higher unit price and larger quantities. The cheaper route is a stock shape with a distinctive label or outer carton. For most brands that is the right decision.

The name and address of the responsible person, the nominal content, the shelf life or the open-jar symbol, the batch number, the function of the product, the list of ingredients under Ingredients or INCI, and the precautionary warnings. The batch number and the warnings are set by us, at the manufacture of each batch and during development.

On the packaging page there is an interactive label where every statement is numbered and explained.

Only the precautionary warnings and the list of ingredients may move onto an enclosed leaflet. Everything else has to stay on the primary pack, however little room there seems to be. If you do move them, the pack has to carry the hand-and-book symbol telling the user to look for those details on the enclosed material.

For soaps, bath bombs and similar small items the Regulation allows the list of ingredients to stand on a notice immediately beside the product on the shelf. That is the only such case.

It is the PAO mark and it says how many months the product stays usable and unchanged after opening. It is used where the shelf life is longer than 30 months. Where the shelf life is 30 months or less, a date of minimum durability has to be given instead of the jar symbol. That is a common mistake. The PAO is set after testing, from four sources: the stability test, the challenge test, the microbiological quality of the batch, and the packaging chosen.

The Regulation prescribes no size, but it does require indelible, easily legible and visible lettering. In practice that means roughly a millimetre at least. The list of ingredients is usually the smallest element on the label and still has to read normally.

The printer needs a PDF to PDF/X-1a:2001 or PDF/X-4, in CMYK, at 300 dpi at final size. Bleed is 3 mm on every side and the safe area 3 mm inwards. The cut line has to be a separate spot colour on its own layer, marked as non-printing. Fonts have to be embedded or converted to outlines. White must never overprint, or it simply disappears in print.

The width of the label is the girth less 10 mm, so the label does not overlap itself. The height is the height of the pack less 5 mm at the top and 5 mm at the bottom. Where the pack is rounded, take only the straight part of the wall as the height, not the whole height of the container. There is a calculator for this on the packaging page.

Most often digital label printing, screen printing directly onto the pack, and thermal transfer. Digital printing suits short runs and many colours. Screen printing gives a strong, durable mark on the pack itself. Thermal transfer is fused into the label, so it is effectively indelible. Which method is right depends on the material of the pack, its shape and the number of colours.

No. Parabens are preservatives permitted in the EU at set maximum concentrations. A free-from claim presents them as harmful and so denigrates a lawfully permitted ingredient, which the fairness criterion expressly forbids. The same holds for silicone free, sulphate free and the like.

No. Every substance is a chemical, water and vitamins included. The word describes the chemical composition of a substance, not its harmfulness. The claim is scientifically wrong and therefore misleading.

Only if you have genuinely reduced the allergenic potential and can prove it. It must not promise that an allergic reaction is impossible, because nobody can guarantee that. It is decided at the first version of the formula, not afterwards. Known allergens have to be excluded then, including the 26 fragrance allergens that must be declared on the label.

It means the effect was measured with an instrument on a panel of people, to a pre-defined protocol and with statistical analysis against a baseline. The claim may state exactly what was measured and nothing beyond it. The outcome is not guaranteed, since a study can equally show no difference.

Natural is not defined in law. So it has to be clear what it refers to, and supported by a calculation of the share to ISO 16128. Organic makes sense only within a certification standard you have actually obtained. Without the certificate the claim is unsupported.

There is no legal definition in cosmetics, but the claim has to hold true across the whole supply chain, traces of animal-derived ingredients included. You support it with supplier declarations for every raw material, collected during development. For a mark on the pack you apply to the trademark holder.

Only where the factor has been measured by the prescribed methods, ISO 24444 for SPF and ISO 24443 for UVA, and the product labelled in the prescribed categories. Terms such as total protection, sunblock or all-day protection are not permitted.

No. Those are medicinal claims. Attributing treatment or a change in bodily function to a product takes it out of cosmetics and into medicines, with an entirely different approval route.

We go through the claims with you while the documentation is prepared, before the packaging goes to print rather than after. On the Our vision page there is a tool covering eighteen common claims. It says whether a claim is permitted and, for those that can be earned, how they are proved and how long the evidence takes.

It means the product contains ingredients of natural origin, that is materials found in plants and other natural settings, minimally processed. It does not necessarily mean they were organically grown, and it does not mean they were really extracted from plants. They can be made in a laboratory, chemically identical to what occurs in nature.

There is no universal definition. Most products are more than 60 per cent water, which also qualifies as a natural material.

Organic cosmetics is about how the materials were grown. It means materials free of pesticides and of genetically modified organisms, certified by bodies such as COSMOS, Ecocert or USDA Organic. Natural speaks of where an ingredient comes from, organic of how it was produced. Organic is the better defined of the two, because a certificate with its own rules stands behind it.

The term concentrates on the safety of ingredients and excludes those said to be potentially harmful, whether of natural or synthetic origin. It is worth reading critically. Every so often word goes round that one ingredient or another is dangerous, though there is no evidence for it. The purpose is often psychological, to have the buyer replace an entire shelf and buy something new.

A marketing tactic where a company trades on the popularity of natural and sustainable cosmetics without the product actually meeting those standards. The signs are vague labels with no certificate behind them, a minimal share of natural ingredients, and often a star ingredient made much of although there is very little of it in the product.

Not necessarily. Plant materials are a frequent cause of allergic reactions, essential oils and extracts above all. Cosmetics that are 100 per cent natural in the way a buyer imagines them do not really exist. And rightly so, since it would do more harm than good. Without proper preservation the product becomes a culture medium for bacteria and moulds.

They are ingredients chemically identical to natural ones but obtained in a laboratory rather than directly from a plant. Hyaluronic acid from fermentation and bakuchiol are two examples. As a rule they are more sustainable than classical extraction, since they do not deplete plant sources. They often make a product vegan as well.

Most often not because of a dangerous ingredient but because of the state your skin is in. Broadly there are two reasons, allergy and sensitivity. Cosmetics on the EU market are strictly regulated and the chance that you bought an unsafe product is very small. Even extensively tested products provoke unwanted reactions in some users.

An allergy is a response of the immune system to an ingredient the body reads as foreign. It is often congenital and as a rule lifelong, though it can also appear alongside major hormonal or bodily changes. A sensitivity, or irritation, is not an immune response but the consequence of a weakened skin barrier letting ingredients penetrate too deeply. In practice it is a good deal commoner, and it usually passes once the skin or the circumstances change.

Which is why it is sometimes worth simply putting the product away and trying it again in a month or two.

Do a patch test, keep to a simple routine of ingredients you know, and do not introduce several new products at once. Strengthen the barrier with humectants and lipids, and choose products at a pH between 5.0 and 5.5, which is the skin's own. If a reaction does happen, use mild soothing products, ideally on a pharmacist's advice.

You can, as long as you understand that you take on responsibility for microbiological soundness, contraindications and allergic reactions. Herbs and plant materials from a garden or a wood are not cleared of allergens and can be dangerous for people with allergies and for children. That goes for essential oils above all.

There is nothing wrong with playing with cosmetics yourself. It is only worth knowing the risks.